COMPLIANCE GUIDE · 10 MIN READ

EU Digital Product Passport 2027: What every manufacturer needs to know

The EU is mandating digital product passports for batteries, machinery, and eventually all physical products. Here is a plain-English guide to what the law requires, who it affects, and how to get compliant before the deadlines hit.

Machinery deadline: January 14, 2027

EU Machinery Regulation 2023/1230 applies from this date. There IS transitional relief, and it is worth knowing: machinery lawfully placed on the market under Directive 2006/42/EC before 14 January 2027 may still be made available afterwards, and EC type-examination certificates issued under that Directive stay valid until they expire. What changes on the date is the regime new machinery is placed on the market under.

Compliance timeline

Jan 14, 2027

EU Machinery Regulation 2023/1230 applies: instructions and Declaration of Conformity default to digital

Feb 18, 2027

Battery Passport mandatory: industrial > 2 kWh, EV, and LMT batteries

2028 (expected)

First ESPR delegated acts expected: textiles, steel, aluminium, furniture, tyres

2030 (expected)

DPP rolling out across ESPR priority categories via delegated acts

What data do you need to provide?

Each regulation specifies what information must be in the digital passport. Here is what each one requires:

Battery Passport (EU 2023/1542)

Manufacturer identity and address

Battery model, category, chemistry

Carbon footprint per kWh (raw materials through end of life)

Recycled content % (cobalt, lithium, nickel, lead)

Expected lifetime in cycles and years

End-of-life recycling and disassembly info

Due diligence on raw material suppliers

Machinery Technical File (EU 2023/1230)

Machine identification and serial number

Declaration of Conformity + notified body

Essential Health & Safety Requirements checklist

Risk assessment reference

Harmonised standards applied (EN ISO 12100…)

Technical drawings and schematics URL

Instructions for use in all EU languages

Cybersecurity documentation (if networked)

Generic DPP (EU 2024/1781)

Manufacturer name and product model

Carbon footprint (kgCO₂e)

Repairability score and spare parts availability

Recycled content and recyclability rate

Substances of concern

CE marking and applicable regulations

Declaration of Conformity URL

How AAS makes compliance tractable

The regulations do not specify a single file format, but the IDTA has published standardized AAS submodel templates that map to the regulation's required data fields. When you fill in a Battery Passport submodel in AAS Studio, you produce the structurally valid file the regulation's data model expects. Legal conformity is a separate step: you declare most of it yourself under internal production control, and a notified body must be involved for the carbon footprint and recycled content figures.

The AAS format is also machine-readable, meaning downstream systems, such as your customers' ERP, logistics platforms, and recyclers, can ingest it automatically without manual data re-entry.

Who is affected?

Battery manufacturers

EU 2023/1542

Deadline: 2027

Machinery OEMs

EU 2023/1230

Deadline: Jan 2027

Automotive tier suppliers

CATENA-X CX-0006/0026

Deadline: Now

Electronics manufacturers

EU 2024/1781 ESPR

Deadline: 2028 to 2030

Importers to EU market

All of the above

Deadline: Same as OEMs

Authorised representatives

As economic operator

Deadline: Same as OEMs

Start building your DPP today

AAS Studio has pre-built templates for every EU regulation listed above. Start for free, no credit card required.